2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.